Jane owns all of the shares of J Ltd., a Canadian-controlled private corporation with investments in numerous Canadian public companies. Her husband, Mike, owns all of the shares of M Ltd., a Canadian-controlled private corporation, with excess cash. They have decided to have M Ltd. purchase the shares of J Ltd. in order to provide Jane with the cash required to take advantage of another investment opportunity. The shares of J Ltd. are currently worth $900,000 and have a PUC and ACB of $100,000. The plan is for M Ltd. to pay Jane $900,000 in cash for the J Ltd. shares. Income tax reference: ITA 84.1
Determine the tax consequences for Jane.